But concern about access to site 5 in view of the narrow nature of Old Warwick Road and proximity to humpback bridge over canal and low bridge under railway.

However hydrology modelling is definitely needed for sites 1, 2 and 6

Please refer to my letter to the Development Policy Manager dated 30 December 2013

Preferred option sites 1, 2 and 6 are immediately adjacent to the Grand Union Canal. Proposed developments in this location should not adversely affect the integrity of the waterway structure, quality of the water, result in unauthorised discharges and run off or encroachment; detrimentally affect the landscape, heritage, ecological quality and character of the waterways; prevent the waterways potential for being fully unlocked or discourage the use of the waterway network.

The preferred option sites 1, 2 and 6 are towpath side of the canal and there are visitor moorings adjacent to sites 1 and 2. It will be important to ensure that an assessment as to whether residential development as proposed could satisfactorily co-exist adjacent to the moorings without affecting the provision of moorings in this location due to potential complaints from new residents due to noise, boat movements etc.is undertaken. The Canal & River Trust would not support the loss of these moorings which are in constant use due to the proximity to Kingswood Junction.

There are also canal structures in proximity to preferred option sites 1, 2 and 6 which need to be taken account of such as culverts, aqueduct, bridges, and a number of listed buildings at Kingswood Junction.

The waterways can be used as tools in place making and place shaping, and contribute to the creation of sustainable communities. Canal & River Trust would seek for any development to relate appropriately to the waterway and optimise the benefits such a location can generate for all parts of the community.

I support the preferred options but note that significant flooding issues need to be addressed for sites 1,2 and 6.

Houses should not be built in high flood risk area's. Sites 1, 2 & 6 are classed by the environment agency as high flood risk area's.

The development of Sites 1 and 2 opposite Site 6 will lead to a crossroads, close to a blind canal bridge. This is a health & safety issue.

Houses should not be built in high flood risk area's. Sites 1, 2 & 6 are classed by the environment agency as high flood risk area's.

The development of Sites 1 and 2 opposite Site 6 will lead to a crossroads, close to a blind canal bridge. This is a health & safety issue.

I support the preferred options. However, there are significant flooding issues associated with sites 1, 2 and 6. It is essential that any mitigation measures should consider not only the sites per se but also the surrounding areas.

support this proposal

The revised proposals for Kingswood, under the new local plan, seem to be a much more favourable option than originally proposed. We have no objection to these revised proposals.

Introduction
This submission is made on behalf of the Kingswood Residents' Group consisting of residents in the Kingswood area of Lapworth.
The Kingswood Residents' Group welcomes the fact that Warwick District Council has taken note of the concerns raised independently in their responses to the Revised Development Strategy Consultation of June 2013 by the Kingswood Residents' Group, Lapworth Parish Council and the Lapworth Parish Plan Steering Group in relation to the disproportionate number of dwellings proposed for Kingswood (Lapworth) in that June 2013 Strategy. The Kingswood Residents' Group is of the view that the proposal of 62 dwellings in the current Village Housing Options & Settlement Boundaries Consultation is a proportionate number. Consequently, the Kingswood Residents' Group supports the current proposals including the proposed new village envelope. However, it is believed that clarification is required regarding the following issues: phasing of development, windfalls, flooding, and character of future developments. Each of these issues is considered below.
Phasing
RDS5 of the June 2013 Revised Development Strategy indicated that development in Kingswood (Lapworth) would be spread over the three Plan Phases 1, 2 and 3. However, as stated in Section 6.3, the current consultation document does not go into detail about the phasing of individual sites. In order to ensure a smooth integration of the new developments into the village, the Kingswood Residents' Group believes that they should be phased over the full duration of the Local Plan (ie up to 2029) rather than all built in the early years.
Windfalls
In its response to the June 2013 Revised Development Strategy the Kingswood Residents' Group noted that in Section 4.2.3 of that Strategy an estimate of 2,800 windfall sites had been made, but that there was no clarity on either their location or their nature other than that WDC had informed us that the rural figure was 504. The possible implications for a village, such as Lapworth, were not clear and were of concern. This situation has not changed and clarification would be helpful
Flooding
Residents are aware that several of the seven Preferred Option Sites in Kingswood are prone to flooding and, indeed, the Consultation Document states that two of the sites (1 and 6) will "need to be subject to detailed hydrology modelling". We would welcome assurance that the modelling will not be confined to the sites per se but will include the implications for the areas adjacent to the sites, and that any mitigation measures will not make matters worse for the surrounding areas but will improve them.
Character of Future Developments
It is understood that Warwick District Council's benchmark figure for affordable housing is still 40%. The Kingswood Residents' Group is of the view that this figure is too high for Kingswood (Lapworth) where there is a lack of local employment and very poor public transport provision. Furthermore, irrespective of the benchmark figure, we are of the view that priority to affordable housing should be given to people with local family connections.
Summary
The Kingswood Residents' Group supports the proposals in the Village Housing Options & Settlement Boundaries Consultation Document for a total of 62 dwellings in Kingswood and for the new village envelope, but requests that further consideration and clarification be given to the phasing of development, the implications of windfalls, flooding studies, and the character of future developments.

I should like to register my following comments in relation to the current consultation on Warwick DC's New Local Plan with respect to the Kingswood, Lapworth, area:

I should like to register my overall support for Warwick DC's revised new local plan for the Kingswood area. I am reassured to see that account has been taken of residents' concerns about the previous number of houses proposed and believe that the current proposal for 62 houses is proportionate to the area within the village envelope (a proposed increase of 15%). I also recognise that Warwick DC has taken into account the environmental and asthetic impact on a number of originally proposed sites which have now been discounted. I support in principle the sites proposed as they do not include one overall site with a substantial number of properties which would cause significant negative impact. However, I should like Warwick DC to consider the following:
* That a full survey be completed to understand the impact of flooding on all of the proposed sites and that the surrounding areas should be taken into account - ie I believe it could potentially cause flooding issues for other parts of the village if each site is considered only in isolation.
* I believe that the building should take place over the whole period of the plan and not just in the early years to better manage integration and impact.
* I have concerns that the impact of windfall has not yet been clarified/explored and would not want to see 62 houses built only for further housing then to be built within the village due to windfall - this would potentially put unacceptable pressure on the location
* Levels of affordable housing. I understand the pressures felt by Warwick DC in its obligation to provide affordable housing within its jurisdiction, and I am supportive of the principle - however I would like Warwick DC to consider that affordable housing within Kingswood at the levels it is proposing is potentially unrealistic. The Council's own data indicates that the majority of residents within Kingswood are witihn professional occupations who travel by car or by train to their employment - there is very limited job opportunities within the village itself and very poor transport links - other than at commuter times into Birmingham city centre (of no use to shift workers for example). Local facilities are also quite expensive and potentially too expensive for occupants within affordable housing. I am supportive of affordable housing being available to those with links to the area (similar to other rural communities with local occupancy clause)- eg older community wishing to remain in the area but wishing to downsize(council's data indicates a signifcant rise in the number of pensioners in the area), and those within the 18-30yrs category that currently struggle to get onto housing market.

I am pleased to see that the revised Plan more clearly reflects the feelings and wishes of the village. The reduced number of dwellings is far more reasonable for Kingswood. The preferred sites are of a smaller size and therefore also more suitable for a rural village location.


However, there are some concerns which I feel need to be addressed before the Plan is finalised.

The increase of 62 dwellings should be phased over the full period of the Plan, i.e. to 2029, to avoid any sudden large increase in the number of residents, which would cause problems with the existing limited infrastructure. This has been requested before,but so far we have had no reassurance from the council on this.

Over the period of the Plan, any "windfall sites" should be included in the number of 62 new dwellings permitted. We have also sought clarification on this point before, and had no response from the Council.

The preferred sites are all central in the village, and consequently the increased traffic could pose a problem in an area that already suffers from congestion due to parking around the Village Shop, the garage, and the school, and problems at the junction of Brome Hall Lane, and the entrances to the surgery and village hall. Particular attention should be paid to ways of mitigating the impact of extra traffic in these areas.

There are flooding issues in many parts of Kingswood, and an increase in the number of dwellings must have some effect on these areas. Therefore it is important to have a thorough investigation of the sites before any new building is permitted, to ensure that appropriate measures are taken to prevent flooding being increased in either these areas, or those adjacent.

The brown line of the settlement boundary, as shown in your proposed Plan, should remain the defining boundary for all development for the duration of the plan, with no land outside it being made available for development, and any sites within it being allowed only at the density level of existing housing.. No large scale developments should be allowed which are inappropriate for the area.

There is a shortage of housing in the area for both first-time buyers, and young families. Therefore any Affordable Housing should first and foremost be made available to those with local connections.

I would hope that the Council would take all these points in to account, and consider the wishes of all the local residents, before finalising the details of the proposed Local Plan.

Please find attached a completed Village Housing Option Response Form submitted on behalf of Business Flats Ltd, the owners of land (Site No 6) at Kingswood, Warwickshire.

see attached

I refer to the above consultation on the draft Local Plan which commenced in 2011. Sites are now being considered as preferred options in a high risk flood plain, at which a number of properties have been flooded, when other sites at risk of flooding have been dropped. The Planning Department have previously been provided with photographs of flooding and the impact of flooding at these sites.

In the initial consultation undertaken by your Council, 57 respondents were against
Development and only 5 in favour. Those in favour being either developers or landowners wanting to develop their land. How can you call this process consultation, when the outcome of such consultation is totally disregarded?

Any proposals for affordable housing should meet the statutory criteria for affordable housing and should be pursued through the Rural Housing Trust and not under the control of developers, landowners and/or local charities.

Why have decisions been made to include sites as preferred options in a high risk flood plain, without the Environment Agency being consulted?

The restricted culvert under the canal at site 1 and also the restricted culvert under the Old Warwick Road, create bottlenecks and have resulted in flooding. Will the Highway Authority accept responsibility for flooding if development is permitted, but the culvert under the Old Warwick Road is left as it is at present.

The proposed development is over intensive and will affect the character of the surrounding area, including watercourses and listed buildings, and will clearly impact on such buildings and the local street scene as well as being detrimental to the amenities of adjoining residents.

The proposed access/egress points of sites 1, 2 and 6 on the Old Warwick Road, are at the foot of a hill, on a bend and at a point where traffic does speed, and also adjoin, or are opposite listed buildings.

Allowing a development of this magnitude in the area does not take into account the lack of available public transport. Any younger people taking up residence in the area will need to rely on cars to travel to work, bearing in mind, there is very little chance of local employment.

The time for emergency services to reach the area is a minimum of 10/15 minutes and is probably in reality, a lot longer. This will impact on the elderly requiring emergency hospital treatment.

There is a legal challenge by a number of parish and town councils over the housing quota put forward by Warwick District Council. If this challenge is successful, it would bring into serious question, the whole of the Local Plan put forward by Warwick District Council. By not awaiting the outcome of this challenge, I think Warwick District Council could be seen as negligent in trying to steam roller through what could turn out to be a flawed Local Plan.

If there is any development proposed in the local plan for the parish of Rowington, other identified sites which are not in a high risk flood plain and which would equally serve the local community should also be considered for development.

Any proposed development should be infill and not backfill.

It is felt that there is insufficient local infrastructure, in particular, the sewage system which in a number of areas, still combines both storm water and foul water.

Settlement Boundaries Consultation

It is sad that you feel it necessary to alter the village settlement boundaries. A few years ago, Rowington Parish Council undertook a poll of local residents in Rowington (Kingswood) who by a substantial majority voted for no changes to be made to parish boundaries, since they all had ties and attachments to Rowington and not Lapworth, and more recently by local residents responding to the Boundary Consultation process undertaken by your Council. Please leave Rowington out of the village settlement boundary.

N.B. The following response is the result of Working Party discussions between Rowington Parish Councillors and is therefore subject to formal resolution at the next Council Meeting on February 13th 2014.

1. The results of the recent Parish Design Statement Survey confirmed that a significant number of respondents identified the need for smaller housing units to accommodate both young families with historical roots in the Parish and existing elderly residents wishing to downsize and remain in the parish. Only 17% of residents wished to leave Rowington Parish upon retirement. Anecdotal evidence also supports the view that many young families will already have left Rowington Parish and therefore would not have participated in the survey.
It is appreciated that Warwick District Council are only likely to undertake preliminary analysis of the suitability of sites, with full design solutions being the responsibility of the developers. Where significant infrastructure works are required to overcome specific site issues, the Parish Council is concerned that initial development proposals, which are acceptable to residents and the Parish Council, may not then be financially viable to the developer, or acceptable to WDC, at the density and layout originally proposed. This may lead to pressure being applied to the planners to accept a higher density proposal, or one that is inappropriate, leading perhaps, to withdrawal of the PC's support.
Rowington Parish Council wishes to safeguard the interests of residents who might be directly affected by future developments. However, Rowington Parish Council has no objection in principle to Warwick District Council undertaking further investigation of the Kingswood sites, which are located within the Parish of Rowington, in order to ascertain whether those sites are suitable for development. This agreement is based on further consultation, including the following conditions.

1. Sight of detailed hydrology modelling on sites 1 and 6.
2. Application of criteria based on recent actual occurrence of flooding, to ensure that deficiencies in the hydrological models do not allow development on land prone to flooding without diligent attention to flood mitigation and prevention, particularly with regard to the land to the rear of Kingswood Cottages.
3. Sight of outline proposals regarding housing numbers, to include housing design and mix of housing type/size.
4. Sight of outline and detailed landscaping proposals to include site screening.
5. Agreement and confirmation of the indicative settlement boundary for Kingswood village.
2. Other Sites
Rowington Parish Council has been asked to give consideration to possible small scale development at Rowington and Lowsonford, namely Areas R132, R133 and R152 in the Location Plan of Rowington dated 25 September 2013. These have been stated to be presently off the agenda for the Local Plan.
Continued........../

Continuation....... /

Parish Councillors have recently become aware that Rowington Almshouse Charity has expressed interest in developing further almshouses which it considers are needed within the parish. The Parish Council believes that these almshouses permit elderly and less affluent residents to remain within the parish, with the additional benefit that a homogeneous mix of residents is retained, as far as possible, within the community.
Specifically, Area R133, adjacent to land already owned by Rowington Almshouse Charity, has been identified by the Charity and the Parish Council believes that this should be looked upon favourably by parishioners and the Parish Council. Such support is a requirement of Paragraph 2.16 in the draft Local Plan.
Rowington Parish Council would therefore be prepared to consider, in principle, other small scale developments where appropriate, subject to normal planning rules and including sight of development and traffic management proposals where applicable. In addition, confirmation of site suitability and sustainability, including confirmation that existing drainage facilities have adequate capacity to facilitate the developments at the indicative densities, given the extremely limited infrastructure available in all areas of the parish.

see attached